ML20118A752
| ML20118A752 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 09/19/1992 |
| From: | Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 102-02279-WFC-G, 102-2279-WFC-G, NUDOCS 9209250279 | |
| Download: ML20118A752 (14) | |
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Arizona Public Service Company eomeom. n m, mzona, >
102-02279-WfC/GMA
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September 19, 1992
,~, m U. S. Nuclear Regulatory Commission ATTN: Docurnent Control Desk Mail Station P137 Washington, DC 20555
Dear Sirs:
Subjec: Palo Verde Nucicar Generating Station (PVNGS)
Units 1,2, and 3
]
Docket Nos. STN 50-528D29/530 Reply to Notice of Violot% 50 528/92 26 01, 50 529/92 26-02, ahc 00 bD/92 26-03 Ell 9: 92-pig-02A Arizona Public Service Company (APS) has reviewed NRC Inspection Report 50-526,629, 530/92 26. Pursuant to the provisions of 10 CFR 2.201, APS' response are enclosed.
Appendix A to this letter is a restatement of the Notice of Violations. APS' responses are provided in Enclosure 1. Per a telephone conversation on August 28,1992, between L. L. Coblentz, NRC, and T. R. Bradish, APS, the due date for this response was extended from September 14, 1992, to Septembcr 21, 1992.
This extension was nacessary because of mail delays transmitting the i4ctice of Violations.
If you should have ariy questions, please contact Thomas R. Bradish at (602) 393-5421.
Sincerely, hiiU A)
WFC/ GAM /pmm
Enclosures:
Appendix A Restatement of Notice of Violations F.nclosure 1 - Reply to Notice of Violations i
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J. B. Martin J. A. Sloan lh
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APPENDIX A RESTATEMENT OF NOTICE OF VIOLATIONS 50-528/92-26-01, 60-529/92-26-02, AND 50-529/92-26-03 NRC INSPECTION CONDUCTED JULY 20 - 24,1992 3
INSPECTION REPORT NOS,50-528,529 AND 530/92-26 M
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' BEST_ATEfLENT OF NOllCE OF VIOLATIOBS 50 52E9236-01. 50 529/02 26-02 AND 50 529/92 26 02 1
During an NRC inspection conducted Jtly 20 - 24, 1932, three violations of NRC requirements were identified. In accordance with the " General Statement Policy and Procedure for NRC Enforcement Action," 10 CFR Part 2, Appendix C, the violations are j
listed below:
A. Viol 31lpn 50-52EQ2 26 02 10 CFR 20.203,c) requires that each high radiation ares ao consplet'ausly posted with a sign or signs bearing the radiation caution symbol and the words: " Caution High 1
Radiation Area."
Contran/ to the above, on July 24,1992, a high radiation area near the ref. ling water storage tank in the Unit 2 outdoor storage yard was not posted as required.
This is a Severity Levol IV violation (Supplement IV) (applicable to Unit 2).
i D. ylolgtlon 50 529/92 26-03 10 CFR 20.201(b) requires that each licensee make such surveys as may be necessary to comply with the rcovirements of Part 20 and which are reasonable under the circumstances to eva!uate the extent of radiation hazards that may be present. As defined in 10 CFR 20.201(a), " survey" means an evalu%on of the radiation hazard incident to the production, use, release, disposal, or presence of mdioactive materials or other sources of radiation under a specific set of conditions.
10 CFR 20.401(b) requires that records be maintained of surveys performed pursuant to 10 CFR 20.210(b).
Contrary to the above, as of July 24,1992, the licensee had not maintained records of a survey performed to assess the radiological hazards associated with the presence of radwaste drums in a storage area adjacent to the Unit 2 refueling water storage tank.
This is a Severity Level IV violation (Supplement IV) (applicable to Unit 2).
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'C VLola11on 50 52JL923EQ1 Technical Specification (TS) 6.12 requires controls to be used for individuals entering an area in which radiation fields are greater than 100 millirem / hour but less than 1000 mill (er%our. Those controls must include either an alarming dosimeter, a portable sunity 'astrumrd, or radiation protection technician (RPT) coverage.
TS 6.11 requires procedures for personnel radiation protec+ ion to be prepared consistent with 10 CFR 20, and requires that these procedures be adhered to for all activities involving personnel radiation exposure.
Licensee Procedure 75AC 9RP01,
- Radiation Exposure and Access Control, Section 2.1, requires individuals to comply with all standard operating procedures, warning signs, and barriers that concern radiation or contamination control.
Contrary to the above:
- 1. On December 11, 1991, two workers failed to comply with a high radiation area warning sign when entering the 129' south valve gallery of the Unit 2 Aniliary %ilding, in that the workers did not have alarming dosimeters, a portable survey instrument, or RPT coverage.
- 2. On February 4,1992, a worker failed to comply with a high radiation area warning sign while working in the 120' liquid radwaste evaporator main recycle pump room cf the Unit 2 Radwasts Building, in that the worker d:d not have an alarming dosimeter, a portable survey instrument, or RPT coverage.
- 3. On March 19,1992, four workers failed to comply with a high radiation area warning sign while working in the 70' *B" shutdown cooling heat exchanger room of the Unit
. Auxiliary Building, in that the workers did not have alarming dosimeters, a portable survey instrument, or RPT coverage.
This is a Severity Level IV violation (Supplement IV) (applicable to Units 1 and 2).
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ENCLOSURE 1 I
r REPLY TO NOTICE OF VIOLATIONS 50 528/92-26-01, 50-529/92-26-02,-
- AND 50-529/92-26-03 NRC INSPECTION CONDUCTED JULY 20 - 24,1992 r
INSPECTION REPORT NOS. 50-528,529 AND 530/92-26 1
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BEEJ.Y TO NOTIQ_E _OE! VIOLATION _(A) 50 529/92 26-02 89210p For The Violation The reason for the violation was personnel error when a Radiation Protection Technician (RPT) failed to properly post a High Radiation Area (HRA).
An RPT had been assigned to monitor and survey the placement of pallets holding drums of radioactive waste being moved into the radioactive storage / staging area near the refueling water tank. The RPT had surveyed each of the drums prior to placement on the pallets, and each of the pallets prior to their placement in the storage / staging area.
Individually, the pallets did not create a HRA. However, the RPT neglected to perform an adequate survey of the pallets after placement in :he storage / staging area, and therefore did not identify, or post as such, the HRA that was created by the cumulative effect of the radiation from two pallets in close proximity.
CaritG1!v_e._SicpA_Ibp111aye_Bapn Taken And ThtHesults Achleyed The area around the drums was surveyed and posted as a high radiation area, in accordance with 10 CFR 20.203(c). Walkdowns of the Unit 2 Radiologcal Controlled Area were conducted to ensure there were no similar situations. The RP Managers of PVNGS Units 1 and 3 were notified of this situr.!:on, as well as all Unit RP Supervisors.
The RPT involved was disciplined under the APS Positive Discipline Program, in addition, RP management issued a directive to RP Supervisors and Technicians in each unit requiring that radwaste containers stored in radwaste storage / staging areas in the radwasia yard reading greater than or equal to 100 mr/hr on contact be located in posted URA's. This directive, which is more conservative than the requirements of plant RP procedures, will eliminate any potential confusion regarding accessible areas in the 1 of 9 l
I radwasta yard that may have existed in the past. Current plans are for this directive to remain in effect until PVNGS implements the revised 10 CFR Part 20, when the posting of HRA's will be more clearly defined.
ponegilygStenslitaLWJILB9 Tahon To Avoid Further Violations Contract RPT's reporting on site for. the upcoming Unit 3 refueling outage will be provided with lessons it,arned from this event, to be completed by September 28,1992.
The General Manager, Site RP, will meet with each of the units' RP Supervisors and Technicians to reinforce management's expectations concerning surveys, posting and control of HRA's, radioactive material control, and radworker communications. This will be completed by October 21,1992.
Lessons learnad from this incident will be presented to site RP technicians in the fourth quarter Industry Events training, scheduled to be completed by January 8,1993.
Date When Full _Co_mplianenJilLBe Achieved Full compliance was achieved on July 22,1992, when the area around the drums was posted as a high radiation area in accordance with 10 CFR 20.203(c).
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BEP_LY TOJOllQLQF VlQ_LATION ID)JM293A25-Q3 Reason For Tttell.9htiqu The reason for the violation was personnel error when a Radiation Protection Technician (RPT) failed to properly survey a High Radiation Area (HRA).
An RPT liad been assigned to monitor and survey the placement of pallots holding drums of radioactive waste be;ng moved into the radioactive storage / staging area near the refucting water tank. The RPT had surveyed each of pallets prior to their placement in the storage / staging area, and individually the pallets did no' create a HRA. However, the RPT neglected to perform an adequate documented survey of the pallets after placement in the storage / staging area, and therefore did not identify the HRA that was -
created by the cumulative effect of the radiation from two pallets in close proximity. Since the RPT incorrectly believed that the posted conditions in the storage / staging area did not change due to the movement of the pallets, he did not document a survey. Current PVNGS procedures do not require a survey to be documented if the posted conditions in an ucea have not changed.
1 991HSJ!vaSicasJhnLHfLve_B_e.gn Taken And The Rpsylte Achieved The area around the drums was surveyed ;n accordance with 10 CFR 20.201(b), and recorded on a survey map that is maintained in accordance with 10 CFR 20.401(b).
Walkdowns of the Unit 2 Radiological Controlled Area were conducted to ensure there were no similar situations. The RP Mana0ers of PVNGS Unite 1 and 3 were notified of inis situation, as well as all Unit RP Supervisors. The RP technician involved was disciplined under the APS Positive Discipline Program.
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In addition, RP management issued a directive to RP Supervisors and Technicians in j
oach unit requiring that a formal documented survey be performed following the movement of radioactive waste barrels into a storage area.
l Conr.g.911ve SleRe_ Thal Will Be Taken To Avoid Further Vi_olallona Contract RPT's reporting on site for the upcom,ng Unit 3 refueling outage will be.
provided with lessons learr d from this event, to be completad by September 28,1992.
The General Manager, Site RP, will meet with each of the Units' RP Supervisors and Technicians to reinforce management's expectations concerning surveys, posting and control of HRA'a, radioactive material control, and radworker communications. This will be completed by October 21,1992.
r RP procedures will be reviewed to identify potential improvements to the survey documentation requirements, cnd the procedures will be revised to incorporate identified improver wnts. The procedurs review will be completed by October 15,1992, and the procedures revised by October 30,1992.
Lessons learned from this incident will be presented to site RPT's in the fourth quarter Industry Events training, scheduled to be completed by January 8,1993.
Date When Full Complian::e Will Be Achieved Full compliance was achieved on July 22,1992, when the area around the drums was surveyed in accordance with 10 CFR 20.201(b), and recordad on a survey map that is maintained in accordance with 10 CFR 20,401(b).
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BEILLY TO NOTICE OF VIOLATION-(C) 50 520192126-01 fleasAn FoLItte._VloLall0D The primary reason for each of the three incidents cited in the violation was personnel error.
i in the incident occurring on December 11,1991, two contract workers did not pay attention to detail when they disregarded postings and improperly entered a posted high radiation area (HRA).
In the incident occurring on February 4,1992, an APS worker did not pay attention to detail ard improperly entered a posted HRA.
In the incident occurring on March 19, 1992, four contract workers apparently misunderstood instructions by a Radiation Protection Technician, and through inattention to detall, improperly entered a posted HRA.
In addition to these three examples cited in the NOV, another incident occurred on August 29,1992. In this incident, two APS workers improperly entered a posted HRA in Unit 1.
This incident has been investigated under the PVNGS incident investigation program. The primary cause of this incident is also personnel error, where the workers failed to pay attention to detail.
As a result of a thorough rnview of the circumstances surrounding each of these incidents, PVNGS management has identified a weakness in that some site personnel may not fully comprehend the importance of and potutial consequences of entering HRA's without proper authorization and controls.
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Qotractive Steas That Have Been Taken And The Resulte Achievqtd i
in each case of unauthorized entry into HRA's, the individuals involved have received appropriate disciplinary action.
In the December 11,199' incident, the two contract workers were released back to the* contract company, with the commitment that they would complete Radiological Work Practices training preor to returning to work at PVNGS. In addition, the contract company reviewed this incident with their other personnel on site.
In the February 4,1992 incident, tho individual involved was disciplined under the APS Positive Discipline Program, in the March 19,1992 incident, the four contract Norkers involved were disciplined by their contract company.
in the August 29,1992 incident, the two workers were interviewed and restricted from t
all work in the Radiological Controlled Area (RCA) pending results of an incident investigation. The workers were disciplined under the APS Positive Discipline Program, and will be required to successfully complete hitial Radiological Work Practices training pricr to being allowed to work in the RCA.
In addition to the actions taken with the individuals involved in each of thsse incidents, the following corrective actions were taken site-wide as initial steps to address this problem:
- 1. On September 1,1992, a one hour site stand-down was ordered by the General Manager, Site RP, with concurrence of the vice President, Nuclear Production. Work was suspended in the RCA. Managers were directed to take this time to ensure that their personnel were made aware of the unauthorized entries into HRA's, and to review 6 of 9 v-o 4
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the requirements for wark in the RCA and entry into HRA'c. It was also emphasized that significant discipline will be taken for any infractions. Following the stand down, RP personnel at the RCA entry points questioned workers before allowing entry to the RCA, to ensure they understood the requirements for entry into HRA's.
- 2. The Vice President, Nuclear Production, issued a memo for dissemination to all site personnel that presented the Company's expectations reparding adherence to RP requirements and repercussions for failing to meet the expectations.
- 3. The Executive Vice President, Nuclear, issued a communicetion to PVNGS management and supervisory personnel emphasizing their responsibility and accountability for their employees' compliance with radiation protection requirements.
- 4. Radiological Work Practices Retraining was revised on September 1,1992, to include added emphasis to the requirements for entry into posted HRA's.
_Qo_rigpRve StensJhat Will_Be Tpken To Avoid Furttter Violations r
The following corrective steps will be taken within the RP Department:
1.-Contract RPT's reporting on site for the upcoming Unit 3 refueling outage will be provided with lessons learned from these incidents, to be completed by September 28,-1992.
- 2. The General Manager, Site RP, will meet with each of the Units' RP Supervisors and Technicians to reinforce manageraent's expectations concerning surveys, posting and control of HRA's, radioactive material control, and radworker communications. _ This-will be completed by October 21,1992.
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- 3. RP personnel will evaluate the techniques currently utilized to identify HRA's in order to determino if the barriers can be enhanced from a human factors perspective. This will be completed by October 30,1992.
- 4. Lessons learned from these incidents wl" 00 presented to site RP technicians in the fourth quarter Industry Events training, scheduled to be completed by January 8,1993.
As an interim measure, beginning no later than September 25,1992, projob briefings
. will be conducted between the Work Group Supervisors or RP personnel and employees -
for each job requiring a HRA/ Locked HRA entry, including routine entries. At this prejob briefing, the Work Group Supervisor or RP personnel will ensure that each employee understands the requirements for the HRA/LHRA entry and the ALARA requirements for the job. Prior to allowing RCA entry under a HRA Radiation Exoosure Permit, RP personnel w!'l question workers to ensure that this briefing has occurred and is adequate.
While this is in e' m, RP w;ll evaluate the effectiveness of this measure to improve worker knowledge and sensitivity. After November 30,1992, RP will modify or terminate th:3 initiativo as necessary with concurrence of Plant Manac rs.
Additionally, a survey of randomly selected radworkers from each of the three PVNGS units will be conducted to assess their retention of radiological work practices training.
Results of the survey will be utilized to enhance the radworker training program as necessary to address any identified knowledge weaknesses.
The survey will be completed by October 9,1992, and the training program will be enhanced as necessary by October 31,1992.
Date When Ful'. Compliance Will Be Aciieved l
Full compliance was achieved in the December 11,1991 incident on December 15, 1991, when the workers exited the posted HRA.
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l Full compliance was achieved in the February 4,1992 incident on February 4,1992, when the worker exited the posted HRA.
i Full compliance was achieved in the March 19,1992 incident on March 19,1992, when j
the workers exited the posted HRA.
l Full compliance was achieved in the August 29,1992 incident on August 29,1992,'
when the worker exited the posted HRA.
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